“Commercial Information...Your organization; service providers; advertising partners Yes (to advertising partners)”
This analysis describes what Gusto's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This clause confirms that commercial information is shared with advertising partners in a manner Gusto classifies as a sale or sharing, which has legal significance under privacy laws such as CCPA.
Interpretive note: The excerpt is structured as a table row, and the interpretation of 'Yes (to advertising partners)' as indicating sale or sharing for targeted advertising is drawn from the table's apparent column structure rather than fully self-contained prose. The canonical claim reflects the most supported reading but the tabular format introduces some interpretive uncertainty.
The updated policy states that Gusto discloses identifiers and internet or electronic usage data to advertising, business, and technology partners. Under U.S. state privacy laws, this disclosure constitutes a 'sale' or 'share' of personal information. The policy now explicitly describes this practice and provides an opt-out mechanism. You can opt out of the sale or sharing of personal information through the Cookies, Analytics, and Other Tracking Technologies section.
View change record →The updated privacy notice now explicitly covers retirement account access and use (401(k), SEP IRA, IRA), expanding the scope of activities governed by Gusto's privacy practices. The policy introduces optional AI-powered integrations that, when enabled, may disclose personal information to third-party AI providers such as OpenAI; Gusto states it will not permit these providers to use the data to train their models. The revised terms also clarify when the privacy notice does not apply (when Gusto acts as a processor or service provider) and direct users to the Employer Data Processing Addendum for those scenarios. You can review the specific AI providers and integration options available through your Gusto account settings before enabling any AI features.
View change record →Your commercial information, including your organization, may be shared with Gusto's advertising partners for targeted advertising purposes.
How other platforms handle this
in the case of Cohere, to potential assignees, acquirers or successors of Cohere if and to the extent such persons need to know such Confidential Information in connection with a potential sale, merger, amalgamation or other corporate transaction...
We will share Personal Data that we collect, such as Account Information with any corporate affiliates...used for the purposes described in this Privacy Policy and generally to operate our business...
Indeed may also exchange security information and threat indicators with third-party industry partners and industry safety coalitions.
"Commercial Information...Your organization; service providers; advertising partners Yes (to advertising partners)Excerpt from Gusto's Privacy Policy
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This clause confirms that commercial information is shared with advertising partners in a manner Gusto classifies as a sale or sharing, which has legal significance under privacy laws such as CCPA.
Your commercial information, including your organization, may be shared with Gusto's advertising partners for targeted advertising purposes.
ConductAtlas has identified this type of provision across 281 platforms. See the full comparison.
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